Double taxation avoidance convention limits source taxation, grants residence primary taxing rights, and defines permanent establishment for business profits. Convention between India and Romania prevents double taxation by allocating primary taxing rights over dividends, interest, royalties and technical fees to the country of residence while limiting source taxation to specified percentages; aircraft profits are exempt at source and shipping profits at source are capped. Business profits are taxable in the other State only if a permanent establishment exists there, and expenses incurred for the permanent establishment, including executive and general administrative expenses, are deductible in determining its profits in accordance with the State's taxation law.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Double taxation avoidance convention limits source taxation, grants residence primary taxing rights, and defines permanent establishment for business profits.
Convention between India and Romania prevents double taxation by allocating primary taxing rights over dividends, interest, royalties and technical fees to the country of residence while limiting source taxation to specified percentages; aircraft profits are exempt at source and shipping profits at source are capped. Business profits are taxable in the other State only if a permanent establishment exists there, and expenses incurred for the permanent establishment, including executive and general administrative expenses, are deductible in determining its profits in accordance with the State's taxation law.
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